Hong Kong Autonomy Act: new sanctions law signed by the president in response to Hong Kong National Security Law

On Tuesday, 14 July 2020, President Donald Trump signed into law H.R. 7440, the Hong Kong Autonomy Act (the Act). The Act had previously passed both Chambers of the U.S. Congress unanimously.

If the Administration enforces the Act to the maximum extent provided for, there could be significant impacts on Asian and multinational banks determined to have engaged in "significant transactions" with certain foreign persons, such as senior Hong Kong or Chinese government officials or Chinese companies, identified by the U.S. government as having eroded Hong Kong's autonomy. There are a range of menu-based sanctions available to the U.S. government for targeting such banks. If the most severe sanctions were applied, the Treasury Department could cause such banks to lose access to the U.S. financial system, including access to U.S. dollar clearing services. The Administration could also designate or take other actions against foreign persons or entities that have been found to have "materially contributed" to the erosion of Hong Kong's autonomy, which could for instance affect companies operating in Hong Kong that facilitate or support the Chinese or Hong Kong government's ability to monitor the populace and/or suppress civil liberties in Hong Kong.

Read More: Hong Kong Autonomy Act: new sanctions law signed by the president in response to Hong Kong National Security Law


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